State of Ohio Environmental Protection Agency
STREET ADDRESS:
Lazarus Government Center
50 W. Town St., Suite 700
Columbus, Ohio 43215
MAILING ADDRESS:
TELE: (614) 644-3020 FAX: (614) 644-3184
www.epa.state.oh.us
P.O. Box 1049
Columbus, OH 43216-1049
Certified Mail
4/9/2009
Frank Noble
Fujitec America, Inc.
7258 Innovation Way
Mason, OH 45040
RE:
FINAL AIR POLLUTION PERMIT-TO-INSTALL AND OPERATE
Facility ID:
1483000504
Permit Number: P0104278
Permit Type:
Initial Installation
County:
Warren
Yes
No
No
No
No
No
No
No
No
No
TOXIC REVIEW
PSD
SYNTHETIC MINOR
CEMS
MACT
NSPS
NESHAPS
NETTING
MAJOR NON-ATTAINMENT
MODELING SUBMITTED
Dear Permit Holder:
Enclosed please find a final Air Pollution Permit-to-Install and Operate ("PTIO") which will allow you to install, modify,
and/or operate the described emissions unit(s) in the manner indicated in the permit. Because this permit contains
conditions and restrictions, please read it very carefully.
Ohio EPA maintains a document entitled "Frequently Asked Questions about the PTIO". The document can be
downloaded from the DAPC Web page, www.epa.state.oh.us/dapc, from the "Permits" link. This document contains
additional information related to your permit, such as what activities are covered under the PTIO, who has enforcement
authority over the permit and Ohio EPA’s authorization to inspect your facility and records. Please contact the Office of
Compliance Assistance and Pollution Prevention at (614) 644-3469 if you need assistance.
The issuance of this PTIO is a final action of the Director and may be appealed to the Environmental Review Appeals
Commission ("ERAC") under Section 3745.04 of the Ohio Revised Code. The appeal must be in writing and describe the
action complained of and the grounds for the appeal. The appeal must be filed with the ERAC within thirty (30) days after
notice of the Director's action. A filing fee of $70.00 must be submitted to the ERAC with the appeal, although the ERAC,
has discretion to reduce the amount of the filing fee if you can demonstrate (by affidavit) that payment of the full amount of
the fee would cause extreme hardship. If you file an appeal of this action, you must notify Ohio EPA of the filing of the
appeal (by providing a copy to the Director) within three (3) days of filing your appeal with the ERAC. Ohio EPA requests
that a copy of the appeal also be provided to the Ohio Attorney General's Office, Environmental Enforcement Section. An
appeal may be filed with the ERAC at the following address:
Environmental Review Appeals Commission
309 South Fourth Street, Room 222
Columbus, OH 43215
If you have any questions regarding this permit, please contact the Hamilton County Dept. of Environmental Services.
This permit has been posted to the Division of Air Pollution Control (DAPC) Web page www.epa.state.oh.us/dapc.
Sincerely,
Michael W. Ahern, Manager
Permit Issuance and Data Management Section, DAPC
Cc:
HCDOES
Ted Strickland, Governor
Lee Fisher, Lieutenant Governor
Chris Korleski, Director
v Printed on Recycled Paper
Ohio EPA is an Equal Opportunity Employer
Printed in-house
State of Ohio Environmental Protection Agency
Division of Air Pollution Control
FINAL
Air Pollution Permit-to-Install and Operate
for
Fujitec America, Inc.
Facility ID:
Permit Number:
Permit Type:
Issued:
Effective:
Expiration:
1483000504
P0104278
Initial Installation
4/9/2009
4/9/2009
4/9/2014
State of Ohio Environmental Protection Agency
Division of Air Pollution Control
Air Pollution Permit-to-Install and Operate
for
Fujitec America, Inc.
Table of Contents
Authorization ..................................................................................................................................................... 1
A. Standard Terms and Conditions .................................................................................................................. 3
1. What does this permit-to-install and operate ("PTIO") allow me to do? .................................................. 4
2. Who is responsible for complying with this permit? ................................................................................ 4
3. What records must I keep under this permit? ......................................................................................... 4
4. What are my permit fees and when do I pay them? ............................................................................... 4
5. When does my PTIO expire, and when do I need to submit my renewal application? ............................ 4
6. What happens to this permit if my project is delayed or I do not install or modify my source? ................ 5
7. What reports must I submit under this permit? ....................................................................................... 5
8. If I am required to obtain a Title V operating permit in the future, what happens to the operating
provisions and PER obligations under this permit? ................................................................................ 5
9. What are my obligations when I perform scheduled maintenance on air pollution control equipment? ... 5
10. Do I have to report malfunctions of emissions units or air pollution control equipment? If so, how must I
report? ................................................................................................................................................... 6
11. Can Ohio EPA or my local air agency inspect the facility where the emission unit(s) is/are located? ..... 6
12. What happens if one or more emissions units operated under this permit is/are shut down
permanently? ......................................................................................................................................... 6
13. Can I transfer this permit to a new owner or operator? ........................................................................... 6
14. Does compliance with this permit constitute compliance with OAC rule 3745-15-07, "air pollution
nuisance"? ............................................................................................................................................. 7
15. What happens if a portion of this permit is determined to be invalid? ..................................................... 7
B. Facility-Wide Terms and Conditions............................................................................................................. 8
C. Emissions Unit Terms and Conditions ....................................................................................................... 11
1. K001, Paint Booth #1 ........................................................................................................................... 12
Final Permit-to-Install and Operate
Permit Number: P0104278
Facility ID: 1483000504
Effective Date: 4/9/2009
State of Ohio Environmental Protection Agency
Division of Air Pollution Control
Authorization
Facility ID:
1483000504
Application Number(s):
A0036602
Permit Number:
P0104278
Permit Description: Installation of one (1) new paint spray booth with HVLP for coating miscellaneous metal
parts using compliance coatings
Permit Type: Initial Installation
Permit Fee: $200.00
Issue Date: 4/9/2009
Effective Date:
4/9/2009
Expiration Date:
4/9/2014
Permit Evaluation Report (PER) Annual Date:
Jan 1 - Dec 31, Due Feb 15
This document constitutes issuance to:
Fujitec America, Inc.
7258 Innovation Way
Mason, OH 45040
of a Permit-to-Install and Operate for the emissions unit(s) identified on the following page.
Ohio EPA District Office or local air agency responsible for processing and administering your permit:
Hamilton County Dept. of Environmental Services
250 William Howard Taft Pkwy.
Cincinnati, OH 45219-2660
(513)946-7777
The above named entity is hereby granted this Permit-to-Install and Operate for the air contaminant source(s)
(emissions unit(s)) listed in this section pursuant to Chapter 3745-31 of the Ohio Administrative Code.
Issuance of this permit does not constitute expressed or implied approval or agreement that, if constructed or
modified in accordance with the plans included in the application, the described emissions unit(s) will operate
in compliance with applicable State and federal laws and regulations.
This permit is granted subject to the conditions attached hereto.
Ohio Environmental Protection Agency
Chris Korleski
Director
Page 1 of 19
Final Permit-to-Install and Operate
Permit Number: P0104278
Facility ID: 1483000504
Effective Date: 4/9/2009
State of Ohio Environmental Protection Agency
Division of Air Pollution Control
Authorization (continued)
Permit Number:
Permit Description:
P0104278
Installation of one (1) new paint spray booth with HVLP for coating miscellaneous metal
parts using compliance coatings
Permits for the following emissions unit(s) or groups of emissions units are in this document as indicated
below:
Emissions Unit ID:
Company Equipment ID:
Superseded Permit Number:
General Permit Category and Type:
K001
Paint Booth #1
Not Applicable
Page 2 of 19
Final Permit-to-Install and Operate
Permit Number: P0104278
Facility ID: 1483000504
Effective Date: 4/9/2009
State of Ohio Environmental Protection Agency
Division of Air Pollution Control
A. Standard Terms and Conditions
Page 3 of 19
State of Ohio Environmental Protection Agency
Division of Air Pollution Control
Final Permit-to-Install and Operate
Permit Number: P0104278
Facility ID: 1483000504
Effective Date: 4/9/2009
1. What does this permit-to-install and operate ("PTIO") allow me to do?
This permit allows you to install and operate the emissions unit(s) identified in this PTIO. You must
install and operate the unit(s) in accordance with the application you submitted and all the terms and
conditions contained in this PTIO, including emission limits and those terms that ensure compliance
with the emission limits (for example, operating, recordkeeping and monitoring requirements).
2. Who is responsible for complying with this permit?
The person identified on the "Authorization" page, above, is responsible for complying with this permit
until the permit is revoked, terminated, or transferred. "Person" means a person, firm, corporation,
association, or partnership. The words "you," "your," or "permittee" refer to the "person" identified on
the "Authorization" page above.
The permit applies only to the emissions unit(s) identified in the permit. If you install or modify any other
equipment that requires an air permit, you must apply for an additional PTIO(s) for these sources.
3. What records must I keep under this permit?
You must keep all records required by this permit, including monitoring data, test results, strip-chart
recordings, calibration data, maintenance records, and any other record required by this permit for five
years from the date the record was created. You can keep these records electronically, provided they
can be made available to Ohio EPA during an inspection at the facility. Failure to make requested
records available to Ohio EPA upon request is a violation of this permit requirement.
4. What are my permit fees and when do I pay them?
There are two fees associated with permitted air contaminant sources in Ohio:

PTIO fee. This one-time fee is based on a fee schedule in accordance with Ohio Revised Code
(ORC) section 3745.11, or based on a time and materials charge for permit application review
and permit processing if required by the Director.
You will be sent an invoice for this fee after you receive this PTIO and payment is due within 30
days of the invoice date. You are required to pay the fee for this PTIO even if you do not install
or modify your operations as authorized by this permit.

Annual emissions fee. Ohio EPA will assess a separate fee based on the total annual emissions
from your facility. You self-report your emissions in accordance with Ohio Administrative Code
(OAC) Chapter 3745-78. This fee assessed is based on a fee schedule in ORC section 3745.11
and funds Ohio EPA’s permit compliance oversight activities. For facilities that are permitted as
synthetic minor sources, the fee schedule is adjusted annually for inflation. Ohio EPA will notify
you when it is time to report your emissions and to pay your annual emission fees.
5. When does my PTIO expire, and when do I need to submit my renewal application?
This permit expires on the date identified at the beginning of this permit document (see "Authorization"
page above) and you must submit a renewal application to renew the permit. Ohio EPA will send a
renewal notice to you approximately six months prior to the expiration date of this permit. However, it is
very important that you submit a complete renewal permit application (postmarked prior to expiration of
this permit) even if you do not receive the renewal notice.
Page 4 of 19
Final Permit-to-Install and Operate
Permit Number: P0104278
Facility ID: 1483000504
Effective Date: 4/9/2009
State of Ohio Environmental Protection Agency
Division of Air Pollution Control
If a complete renewal application is submitted before the expiration date, Ohio EPA considers this a
timely application for purposes of ORC section 119.06, and you are authorized to continue operating
the emissions unit(s) covered by this permit beyond the expiration date of this permit until final action is
taken by Ohio EPA on the renewal application.
6. What happens to this permit if my project is delayed or I do not install or modify my source?
This PTIO expires 18 months after the issue date identified on the "Authorization" page above unless
otherwise specified if you have not (1) started constructing the new or modified emission sources
identified in this permit, or (2) entered into a binding contract to undertake such construction. This
deadline can be extended by up to 12 months, provided you apply to Ohio EPA for this extension within
a reasonable time before the 18-month period has ended and you can show good cause for any such
extension.
7. What reports must I submit under this permit?
An annual permit evaluation report (PER) is required in addition to any malfunction reporting required
by OAC rule 3745-15-06 or other specific rule-based reporting requirement identified in this permit.
Your PER due date is identified in the Authorization section of this permit.
8. If I am required to obtain a Title V operating permit in the future, what happens to the operating
provisions and PER obligations under this permit?
If you are required to obtain a Title V permit under OAC Chapter 3745-77 in the future, the permit-tooperate portion of this permit will be superseded by the issued Title V permit. From the effective date of
the Title V permit forward, this PTIO will effectively become a PTI (permit-to-install) in accordance with
OAC rule 3745-31-02(B). The following terms and conditions will no longer be applicable after issuance
of the Title V permit: Section B, Term 1.b) and Section C, for each emissions unit, Term a)(2).
The PER requirements in this permit remain effective until the date the Title V permit is issued and is
effective, and cease to apply after the effective date of the Title V permit. The final PER obligation will
cover operations up to the effective date of the Title V permit and must be submitted on or before the
submission deadline identified in this permit on the last day prior to the effective date of the Title V
permit.
9. What are my obligations when I perform scheduled maintenance on air pollution control
equipment?
You must perform scheduled maintenance of air pollution control equipment in accordance with OAC
rule 3745-15-06(A). If scheduled maintenance requires shutting down or bypassing any air pollution
control equipment, you must also shut down the emissions unit(s) served by the air pollution control
equipment during maintenance, unless the conditions of OAC rule 3745-15-06(A)(3) are met. Any
emissions that exceed permitted amount(s) under this permit (unless specifically exempted by rule)
must be reported as deviations in the annual permit evaluation report (PER), including nonexempt
excess emissions that occur during approved scheduled maintenance.
Page 5 of 19
Final Permit-to-Install and Operate
Permit Number: P0104278
Facility ID: 1483000504
Effective Date: 4/9/2009
State of Ohio Environmental Protection Agency
Division of Air Pollution Control
10. Do I have to report malfunctions of emissions units or air pollution control equipment? If so,
how must I report?
If you have a reportable malfunction of any emissions unit(s) or any associated air pollution control
system, you must report this to the Hamilton County Dept. of Environmental Services in accordance
with OAC rule 3745-15-06(B). Malfunctions that must be reported are those that result in emissions that
exceed permitted emission levels. It is your responsibility to evaluate control equipment breakdowns
and operational upsets to determine if a reportable malfunction has occurred.
If you have a malfunction, but determine that it is not a reportable malfunction under OAC rule 3745-1506(B), it is recommended that you maintain records associated with control equipment breakdown or
process upsets. Although it is not a requirement of this permit, Ohio EPA recommends that you
maintain records for non-reportable malfunctions.
11. Can Ohio EPA or my local air agency inspect the facility where the emission unit(s) is/are
located?
Yes. Under Ohio law, the Director or his authorized representative may inspect the facility, conduct
tests, examine records or reports to determine compliance with air pollution laws and regulations and
the terms and conditions of this permit. You must provide, within a reasonable time, any information
Ohio EPA requests either verbally or in writing.
12. What happens if one or more emissions units operated under this permit is/are shut down
permanently?
Ohio EPA can terminate the permit terms associated with any permanently shut down emissions unit.
"Shut down" means the emissions unit has been physically removed from service or has been altered
in such a way that it can no longer operate without a subsequent "modification" or "installation" as
defined in OAC Chapter 3745-31.
You should notify Ohio EPA of any emissions unit that is permanently shut down by submitting a
certification that identifies the date on which the emissions unit was permanently shut down. The
certification must be submitted by an authorized official from the facility. You cannot continue to operate
an emission unit once the certification has been submitted to Ohio EPA by the authorized official.
You must comply with all recordkeeping and reporting for any permanently shut down emissions unit in
accordance with the provisions of the permit, regulations or laws that were enforceable during the
period of operation, such as the requirement to submit a PER, air fee emission report, or malfunction
report. You must also keep all records relating to any permanently shutdown emissions unit, generated
while the emissions unit was in operation, for at least five years from the date the record was
generated.
Again, you cannot resume operation of any emissions unit certified by the authorized official as being
permanently shut down without first applying for and obtaining a permit pursuant to OAC Chapter 374531.
13. Can I transfer this permit to a new owner or operator?
You can transfer this permit to a new owner or operator. If you transfer the permit, you must follow the
procedures in OAC Chapter 3745-31, including notifying Ohio EPA or the local air agency of the
Page 6 of 19
Final Permit-to-Install and Operate
Permit Number: P0104278
Facility ID: 1483000504
Effective Date: 4/9/2009
State of Ohio Environmental Protection Agency
Division of Air Pollution Control
change in ownership or operator. Any transferee of this permit must assume the responsibilities of the
transferor permit holder.
14. Does compliance with this permit constitute compliance with OAC rule 3745-15-07, "air pollution
nuisance"?
This permit and OAC rule 3745-15-07 prohibit operation of the air contaminant source(s) regulated
under this permit in a manner that causes a nuisance. Ohio EPA can require additional controls or
modification of the requirements of this permit through enforcement orders or judicial enforcement
action if, upon investigation, Ohio EPA determines existing operations are causing a nuisance.
15. What happens if a portion of this permit is determined to be invalid?
If a portion of this permit is determined to be invalid, the remainder of the terms and conditions remain
valid and enforceable. The exception is where the enforceability of terms and conditions are dependent
on the term or condition that was declared invalid.
Page 7 of 19
Final Permit-to-Install and Operate
Permit Number: P0104278
Facility ID: 1483000504
Effective Date: 4/9/2009
State of Ohio Environmental Protection Agency
Division of Air Pollution Control
B. Facility-Wide Terms and Conditions
Page 8 of 19
Final Permit-to-Install and Operate
Permit Number: P0104278
Facility ID: 1483000504
Effective Date: 4/9/2009
State of Ohio Environmental Protection Agency
Division of Air Pollution Control
1.
This permit document constitutes a permit-to-install issued in accordance with ORC 3704.03(F) and a
permit-to-operate issued in accordance with ORC 3704.03(G).
a)
For the purpose of a permit-to-install document, the facility-wide terms and conditions identified
below are federally enforceable with the exception of those listed below which are enforceable
under state law only.
(1)
b)
None.
For the purpose of a permit-to-operate document, the facility-wide terms and conditions
identified below are enforceable under state law only with the exception of those listed below
which are federally enforceable.
(1)
2., 3., 4., and 5.
2.
The allowable emissions of Hazardous Air Pollutants (HAPs) as identified in Section 112(b) of Title III of
the Clean Air Act from emissions unit K001 shall not exceed 9.9 TPY for any single HAP and 24.9 TPY
for any combination of HAPs. Compliance with the above limitations shall be determined based upon a
rolling, 12-month summation.
3.
The permittee shall collect and record the following information each month for all materials containing
any hazardous air pollutant (HAP)1 that are applied in emissions unit K001:
a)
the name and identification number/code of each coating, thinner, additive, cleanup material,
and any other material containing any HAP;
b)
the name/identification of each individual HAP contained in each material applied (and identified
in Aa@ above) and the pound(s) of each HAP per gallon of each HAP-containing material
applied;
c)
the number of gallons of each coating, thinner, additive, cleanup material, and other material
applied during the month;
d)
for each individual HAP, the total emissions from all the materials employed, in ton(s), i.e., for
each individual HAP, the summation of the products of Ab@ times Ac@ for all the materials
applied during the month, divided by 2,000 pounds;
e)
the total combined HAPs emissions from all the materials employed during the month, in ton(s),
i.e., the summation of all the individual HAPs emissions from Ad@ above;
f)
for each individual HAP, the total emissions during the rolling, 12-month period, i.e., the
summation of the individual HAP emissions, as recorded in Ad@ above, for the present month
plus the previous 11 months of operation, in ton(s); and
g)
the total combined HAP emissions during the rolling 12-month period, i.e., the summation of all
HAP emissions, as recorded in Ae@ above, for the present month plus the previous 11 months
of operation, in ton(s).
1
A listing of the HAPs can be found in Section 112(b) of the Clean Air Act, or can be obtained by
contacting your Ohio EPA District Office or local air agency contact. Material Safety Data
Sheets typically include a listing of the solvents contained in the coatings and cleanup materials.
Page 9 of 19
Final Permit-to-Install and Operate
Permit Number: P0104278
Facility ID: 1483000504
Effective Date: 4/9/2009
State of Ohio Environmental Protection Agency
Division of Air Pollution Control
4.
5.
The permittee shall submit quarterly deviation (excursion) reports to the Hamilton County Department
of Environmental Services that identify the following information:
a)
all exceedances of the rolling, 12-month individual HAP emission limitation for each HAP for all
the coatings, thinners, additives, and cleanup materials employed; and
b)
all exceedances of the rolling, 12-month total combined HAPs emission limitation for all the
coatings, thinners, additives, and cleanup materials employed.
Compliance with the emission limitations in 2. of these terms and conditions shall be determined in
accordance with the following method(s) identified below:
a)
Emission Limitations:
The allowable emissions of Hazardous Air Pollutants (HAPs) as identified in Section 112(b) of
Title III of the Clean Air Act from emissions unit K001 shall not exceed 9.9 TPY for any single
HAP and 24.9 TPY for any combination of HAPs as specified in 2. above. Compliance with the
above limitations shall be determined based upon a rolling, 12-month summation.
Applicable Compliance Method:
Compliance with the HAP emission limitations shall be demonstrated by the methods outlined in
the recordkeeping requirements in 3. above.
Page 10 of 19
Final Permit-to-Install and Operate
Permit Number: P0104278
Facility ID: 1483000504
Effective Date: 4/9/2009
State of Ohio Environmental Protection Agency
Division of Air Pollution Control
C. Emissions Unit Terms and Conditions
Page 11 of 19
Final Permit-to-Install and Operate
Permit Number: P0104278
Facility ID: 1483000504
Effective Date: 4/9/2009
State of Ohio Environmental Protection Agency
Division of Air Pollution Control
1.
K001, Paint Booth #1
Operations, Property and/or Equipment Description:
Miscellaneous metal parts paint spray booth (GFS Model # IFP-16-10-20S) with HVLP air gun
a)
This permit document constitutes a permit-to-install issued in accordance with ORC 3704.03(F)
and a permit-to-operate issued in accordance with ORC 3704.03(G).
(1)
For the purpose of a permit-to-install document, the emissions unit terms and conditions
identified below are federally enforceable with the exception of those listed below which
are enforceable under state law only.
a.
(2)
For the purpose of a permit-to-operate document, the emissions unit terms and
conditions identified below are enforceable under state law only with the exception of
those listed below which are federally enforceable.
a.
b)
d)(9), d)(10), d)(11) and d)(12).
None.
Applicable Emissions Limitations and/or Control Requirements
(1)
The specific operations(s), property, and/or equipment that constitute each emissions
unit along with the applicable rules and/or requirements and with the applicable
emissions limitations and/or control measures. Emissions from each unit shall not
exceed the listed limitations, and the listed control measures shall be specified in
narrative form following the table.
Applicable Rules/Requirements
a.
b.
c.
d.
OAC rule 3745-31-05(D)
Synthetic minor for Hazardous Air
Pollutants (HAPs) to avoid Title V
permitting.
OAC rule 3745-31-05(E)
OAC rule 3745-15-03(D)
OAC rule 3745-17-11(C)
e.
OAC rule 3745-21-09(U)(1)(d)
Applicable Emissions Limitations/Control
Measures
See Section B.2.
See b)(2)a.
See e)(1).
See b)(2)b., c)(1), c)(2), d)(4) through
d)(8) and e)(1).
No owner or operator of a miscellaneous
metal part or product coating line may
cause, allow or permit the discharge into
the ambient air of any Volatile Organic
Compounds (VOC) from such coating line
in excess of 3.5 pounds of VOC per
gallon of coating, excluding water and
exempt solvents.
See d)(1) and e)(2).
Page 12 of 19
Final Permit-to-Install and Operate
Permit Number: P0104278
Facility ID: 1483000504
Effective Date: 4/9/2009
State of Ohio Environmental Protection Agency
Division of Air Pollution Control
(2)
Additional Terms and Conditions
a.
b.
FEPTIO P0104278 for this air contaminant source takes into account the
following voluntary restrictions (including the use of any applicable air pollution
control equipment) as proposed by the permittee for the purpose of avoiding Best
Available Technology (BAT) requirements under OAC rule 3745-31-05(A)(3):
i.
The maximum annual coatings usage for this emissions unit shall not
exceed 5457 gallons per year, as applied, excluding water and exempt
solvents;
ii.
The maximum annual cleanup materials usage for this emissions unit
shall not exceed 100 gallons per year;
iii.
The maximum VOC content of cleanup materials used in this emissions
unit shall not exceed 6.89 pounds VOC per gallon; and
iv.
The emissions of VOC from this emissions unit shall not exceed 9.90 tons
per year.
On February 1, 2008, OAC rule 3745-17-11 was revised to include paragraph
(C), pertaining to control requirements for particulate emissions from surface
coating processes. These control requirements and the associated operational
restrictions, monitoring, record keeping, and reporting requirements contained in
this permit shall become federally enforceable on the date the U.S. EPA
approves paragraph (C) of OAC rule 3745-17-11 as a revision to the Ohio State
Implementation Plan.
The permittee shall operate the dry particulate filter whenever this emissions unit
is in operation.
c)
d)
Operational Restrictions
(1)
The permittee shall install, operate, and maintain a dry particulate filter system for the
surface coating operations in accordance with the manufacturer=s recommendations,
instructions, and/or operating manual(s) with any modifications deemed necessary by
the permittee. The dry particulate filter shall be employed during all periods of coating
application to control particulate emissions.
(2)
The permittee shall expeditiously repair the dry particulate filter or otherwise return it to
normal operations, as recommended by the manufacturer with any modifications
deemed necessary by the permittee, whenever it is determined that the control device is
not operating in accordance with these requirements.
Monitoring and/or Recordkeeping Requirements
(1)
Any owner or operator of a coating line or printing line who elects to demonstrate the
ongoing status of compliance with the applicable emission limitation by means of the use
of complying coatings (i.e., each coating complies with the applicable emission limitation
as applied) shall collect and record the following information each month and maintain
the information at the facility for a period of three years:
Page 13 of 19
State of Ohio Environmental Protection Agency
Division of Air Pollution Control
Final Permit-to-Install and Operate
Permit Number: P0104278
Facility ID: 1483000504
Effective Date: 4/9/2009
a.
The name and identification number of each coating, as applied; and
b.
The mass of VOC per volume of each coating (excluding water and exempt
solvents), as applied.
This information does not have to be kept on a line-by-line basis. Also, if an owner or
operator mixes complying coatings at a coating line, it is not necessary to record the
VOC content of the resulting mixture.
(2)
(3)
The permittee shall collect and record the following information each month for the
coating line.
a.
the name and identification number of each coating and cleanup material
employed;
b.
the volume, in gallons, of each coating and cleanup material employed; and
c.
the total volume, in gallons, of all of the coatings and cleanup materials
employed.
The permittee shall collect and record the following information for the purpose of
determining annual VOC emissions:
a.
the VOC content of each cleanup material, in pounds per gallon; and
b.
the total VOC emissions from all coatings and cleanup materials employed, in
pounds or tons.
(4)
The permittee shall maintain documentation of the manufacturer's recommendations,
instructions, or operating manuals for the dry particulate filter, along with documentation
of any modifications deemed necessary by the permittee. These documents shall be
maintained at the facility and shall be made available to the appropriate Ohio EPA
District Office or local air agency upon request.
(5)
The permittee shall conduct periodic inspections of the dry particulate filter to determine
whether it is operating in accordance with the manufacturer=s recommendations,
instructions, or operating manuals with any modifications deemed necessary by the
permittee or operator. These inspections shall be performed at a frequency that shall be
based upon the recommendation of the manufacturer and the permittee shall maintain a
copy of the manufacturer=s recommended inspection frequency and it shall be made
available to the Ohio EPA upon request.
(6)
In addition to the recommended periodic inspections, not less than once each calendar
year the permittee shall conduct a comprehensive inspection of the dry particulate filter
while the emissions unit is shut down and perform any needed maintenance and repair
to ensure that it is operated in accordance with the manufacturer's recommendations.
(7)
The permittee shall document each inspection (periodic and annual) of the dry
particulate filter system and shall maintain the following information:
a.
the date of the inspection;
b.
a description of each/any problem identified and the date it was corrected;
Page 14 of 19
Final Permit-to-Install and Operate
Permit Number: P0104278
Facility ID: 1483000504
Effective Date: 4/9/2009
State of Ohio Environmental Protection Agency
Division of Air Pollution Control
c.
a description of any maintenance and repairs performed; and
d.
the name of person who performed the inspection.
These records shall be maintained at the facility for not less than five years from the date
the inspection and any necessary maintenance or repairs were completed and shall be
made available to the appropriate Ohio EPA District Office or local air agency upon
request.
(8)
The permittee shall maintain records that document any time periods when the dry
particulate filter was not in service when the emissions unit was in operation, as well as,
a record of all operations during which the dry particulate filter was not operated
according to the manufacturer=s recommendations with any documented modifications
made by the permittee. These records shall be maintained for a period of not less than
five years and shall be made available to the Ohio EPA upon request.
(9)
The federally enforceable permit-to-install and operate (FEPTIO) application for this
emissions unit, K001, was evaluated based on the actual materials and the design
parameters of the emissions unit's(s’) exhaust system, as specified by the permittee.
The AToxic Air Contaminant Statute@, ORC 3704.03(F), was applied to this/these
emissions unit(s) for each toxic air contaminant listed in OAC rule 3745-114-01, using
data from the permit application; and modeling was performed for each toxic air
contaminant(s) emitted at over one ton per year using an air dispersion model such as
SCREEN3, AERMOD, or ISCST3, or other Ohio EPA approved model. The predicted 1hour maximum ground-level concentration result(s) from the approved air dispersion
model, was compared to the Maximum Acceptable Ground-Level Concentration
(MAGLC), calculated as described in the Ohio EPA guidance document entitled
AReview of New Sources of Air Toxic Emissions, Option A@, as follows:
a.
b.
the exposure limit, expressed as a time-weighted average concentration for a
conventional 8-hour workday and a 40-hour workweek, for each toxic
compound(s) emitted from the emissions unit(s), (as determined from the raw
materials processed and/or coatings or other materials applied) has been
documented from one of the following sources and in the following order of
preference (TLV was and shall be used, if the chemical is listed):
i.
threshold limit value (TLV) from the American Conference of
Governmental Industrial Hygienists= (ACGIH) AThreshold Limit Values for
Chemical Substances and Physical Agents Biological Exposure Indices@;
or
ii.
STEL (short term exposure limit) or the ceiling value from the American
Conference of Governmental Industrial Hygienists= (ACGIH) AThreshold
Limit Values for Chemical Substances and Physical Agents Biological
Exposure Indices@; the STEL or ceiling value is multiplied by 0.737 to
convert the 15-minute exposure limit to an equivalent 8-hour TLV.
The TLV is divided by ten to adjust the standard from the working population to
the general public (TLV/10).
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Final Permit-to-Install and Operate
Permit Number: P0104278
Facility ID: 1483000504
Effective Date: 4/9/2009
State of Ohio Environmental Protection Agency
Division of Air Pollution Control
c.
This standard is/was then adjusted to account for the duration of the exposure or
the operating hours of the emissions unit(s), i.e., A24@ hours per day and A7@
days per week, from that of 8 hours per day and 5 days per week. The resulting
calculation was (and shall be) used to determine the Maximum Acceptable
Ground-Level Concentration (MAGLC):
TLV/10 x 8/X x 5/Y = 4 TLV/XY = MAGLC
d.
The following summarizes the results of dispersion modeling for the significant
toxic contaminants (emitted at 1 or more tons/year) or Aworst case@ toxic
contaminant(s):
Toxic Contaminant: xylene
TLV (mg/m3): 434
Maximum Hourly Emission Rate (lbs/hr): 7.25
Predicted 1-Hour Maximum Ground-Level Concentration (ug/m3): 1558
MAGLC (ug/m3): 10338
The permittee, has demonstrated that emissions of xylene, from emissions unit K001, is
calculated to be less than eighty per cent of the maximum acceptable ground level
concentration (MAGLC); any new raw material or processing agent shall not be applied
without evaluating each component toxic air contaminant in accordance with the AToxic
Air Contaminant Statute@, ORC 3704.03(F).
(10)
Prior to making any physical changes to or changes in the method of operation of the
emissions unit(s), that could impact the parameters or values that were used in the
predicted 1-hour maximum ground-level concentration@, the permittee shall re-model the
change(s) to demonstrate that the MAGLC has not been exceeded. Changes that can
affect the parameters/values used in determining the 1-hour maximum ground-level
concentration include, but are not limited to, the following:
a.
changes in the composition of the materials used or the use of new materials,
that would result in the emission of a new toxic air contaminant with a lower
Threshold Limit Value (TLV) than the lowest TLV previously modeled;
b.
changes in the composition of the materials, or use of new materials, that would
result in an increase in emissions of any toxic air contaminant listed in OAC rule
3745-114-01, that was modeled from the initial (or last) application; and
c.
physical changes to the emissions unit(s) or its/their exhaust parameters (e.g.,
increased/ decreased exhaust flow, changes in stack height, changes in stack
diameter, etc.).
If the permittee determines that the AToxic Air Contaminant Statute@ will be satisfied for
the above changes, the Ohio EPA will not consider the change(s) to be a "modification"
under OAC rule 3745-31-01 solely due to a non-restrictive change to a parameter or
process operation, where compliance with the AToxic Air Contaminant Statute@, ORC
3704.03(F), has been documented. If the change(s) meet(s) the definition of a
Page 16 of 19
Final Permit-to-Install and Operate
Permit Number: P0104278
Facility ID: 1483000504
Effective Date: 4/9/2009
State of Ohio Environmental Protection Agency
Division of Air Pollution Control
“modification”, the permittee shall apply for and obtain a final FEPTIO prior to the
change. The Director may consider any significant departure from the operations of the
emissions unit, described in the permit application, as a modification that results in
greater emissions than the emissions rate modeled to determine the ground level
concentration; and he/she may require the permittee to submit a permit application for
the increased emissions.
(11)
e)
The permittee shall collect, record, and retain the following information for each toxic
evaluation conducted to determine compliance with the AToxic Air Contaminant
Statute@, ORC 3704.03(F):
a.
a description of the parameters/values used in each compliance demonstration
and the parameters or values changed for any re-evaluation of the toxic(s)
modeled (the composition of materials, new toxic contaminants emitted, change
in stack/exhaust parameters, etc.);
b.
the Maximum Acceptable Ground-Level Concentration (MAGLC) for each
significant toxic contaminant or worst-case contaminant, calculated in
accordance with the AToxic Air Contaminant Statute@, ORC 3704.03(F);
c.
a copy of the computer model run(s), that established the predicted 1-hour
maximum ground-level concentration that demonstrated the emissions unit(s) to
be in compliance with the AToxic Air Contaminant Statute@, ORC 3704.03(F),
initially and for each change that requires re-evaluation of the toxic air
contaminant emissions; and
d.
the documentation of the initial evaluation of compliance with the AToxic Air
Contaminant Statute@, ORC 3704.03(F), and documentation of any
determination that was conducted to re-evaluate compliance due to a change
made to the emissions unit(s) or the materials applied.
(12)
The permittee shall maintain a record of any change made to a parameter or value used
in the dispersion model, used to demonstrate compliance with the AToxic Air
Contaminant Statute@, ORC 3704.03(F), through the predicted 1-hour maximum
ground-level concentration. The record shall include the date and reason(s) for the
change and if the change would increase the ground-level concentration.
(13)
See Section B.3. of this permit.
Reporting Requirements
(1)
Annual Permit Evaluation Report (PER) forms will be mailed to the permittee at the end
of the reporting period specified in the Authorization section of this permit. The permittee
shall submit the PER in the form and manner provided by the director by the due date
identified in the Authorization section of this permit. The permit evaluation report shall
cover a reporting period of no more than twelve-months for each air contaminant source
identified in this permit.
(2)
The permittee shall notify the Hamilton County Department of Environmental Services of
any monthly record showing the use of noncomplying coatings. A copy of such record
Page 17 of 19
Final Permit-to-Install and Operate
Permit Number: P0104278
Facility ID: 1483000504
Effective Date: 4/9/2009
State of Ohio Environmental Protection Agency
Division of Air Pollution Control
shall be sent to the Hamilton County Department of Environmental Services within thirty
days following the end of the calendar month.
(3)
f)
See Section B.4. of this permit.
Testing Requirements
(1)
Compliance with the emission limitations and voluntary restrictions in b) of these terms
and conditions shall be determined in accordance with the following method(s) identified
below and in Section B.5. of this permit:
a.
Emission Limitations and Voluntary Restriction
No owner or operator of a miscellaneous metal part or product coating line may
cause, allow or permit the discharge into the ambient air of any VOCs from such
coating line in excess of 3.5 pounds of VOC per gallon of coating, excluding
water and exempt solvents.
The maximum VOC content of cleanup materials used in this emissions unit shall
not exceed 6.89 pounds VOC per gallon
Applicable Compliance Method
OAC rule 3745-21-10(B) shall be used to determine the VOC contents of each
coating, thinner, additive, cleanup material, and other material applied. If
pursuant to 40 CFR Part 60, Appendix A, an owner or operator determines that
Method 24 or Method 24A cannot be used, the permittee shall notify the
Administrator of USEPA and shall use formulation data for the material to
demonstrate compliance until USEPA provides alternative analytical procedures
or alternative precision statements for Method 24 or 24A.
b.
Voluntary Restrictions
The emissions of VOC from this emissions unit shall not exceed 9.90 tons per
year.
The maximum annual coatings usage for this emissions unit shall not exceed
5457 gallons per year, as applied, excluding water and exempt solvents.
The maximum annual cleanup materials usage for this emissions unit shall not
exceed 100 gallons per year.
Applicable Compliance Method
Compliance with the voluntary restrictions shall be demonstrated by the methods
outlined in the recordkeeping requirements in d)(2) above.
The VOC emissions voluntary restriction was determined using information
provided by the permittee in PTIO application A0036602 for PTIO P0104278 and
the SIP allowable in the following equations:
5457 gal coatings – H2O & exempt solvents/yr x 3.5 lbs VOC/gal coating – H2O
& exempt solvents x 1 Ton/2000 lbs = 9.55 TPY VOC;
Page 18 of 19
Final Permit-to-Install and Operate
Permit Number: P0104278
Facility ID: 1483000504
Effective Date: 4/9/2009
State of Ohio Environmental Protection Agency
Division of Air Pollution Control
100 gal cleanup materials/yr x 6.89 lbs VOC/gal cleanup materials x 1 Ton/2000
lbs = 0.35 TPY VOC; and
Total 9.55 TPY VOC + 0.35 TPY VOC = 9.90 TPY VOC voluntary restriction.
c.
Control Measures
The permittee shall operate the dry particulate filter whenever this emissions unit
is in operation.
Applicable Compliance Methods
Compliance with the dry particulate filter control measures shall be demonstrated
by the methods outlined in the recordkeeping requirements in d)(4) through d)(8)
above.
d.
g)
See Section B.5. of this permit.
Miscellaneous Requirements
(1)
None.
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